FILED: KINGS COUNTY CLERK 09/18/2017 10:23 AM INDEX NO.

514736/2015
NYSCEF DOC. NO. 120 RECEIVED NYSCEF: 09/18/2017

o
* if

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS

A.J. RICHARD & SONS, INC.

Index No. 514736/2015
Plaintiff,
Part Comm. 11
-against-

FOREST CITY RATNER COMPANIES, LLC, ;

Defendant.

STIPULATION FURTHER EXTENDING DISCLOSURE DEADLINES

WHEREAS, earlier stipulations in this case provided for extensions of the expert disclosure
i deadlines for both Plaintiff A.J. Richard & Son, Inc. (A.J. Richard) and Defendant Forest City

Ratner Companies, LLC (Forest City) (collectively, the Parties), to allow for non-party
/
Greenland Atlantic Yards, LLC (Greenland) to complete its production of documents in

response to a Subpoena for Deposition/Documents (the Subpoena) served on Greenland by A.J.

Richard on February 17, 2017; and

WHEREAS, on September 5, 2017, Greenland made a partial production in response to

the Subpoena, and counsel for Greenland stated that Greenland anticipated producing any

additional documents quickly;

IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel

for A.J. Richard and Forest City, that the remaining disclosure deadlines are extended and
modified
as follows:

A.J. Richard shall provide expert disclosure by: November 1, 201 7;

Forest City shall provide expert disclosure by: December 1, 201 7;

End date for all disclosure: January 1 5, 2018; and

!INYLIT;27546.S.WI Mil 1 7-0&.IM PMfl

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FILED: KINGS COUNTY CLERK 09/18/2017 10:23 AM INDEX NO. 514736/2015
NYSCEF DOC. NO. 120 RECEIVED NYSCEF: 09/18/2017
s

Compliance Conference to be conducted on

Note oflssue date is extended to

i/n/ir
However, if either of the Parties, at any time, have any concerns about the sufficiency and/or timing

of Greenlands response to the Subpoena, the Parties agree to discuss in good faith whether further

extension of these disclosure deadlines is appropriate.

So ordered,
Mfv
Hon. S}/fvia G. Ash, J.S.C.

2
||NYUT-27<6546vS 09/12/20 1 7-02:04 PM)]

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NYSCEF DOC. NO. 120 RECEIVED NYSCEF: 09/18/2017
* -l

IT IS HEREBY FURTHER STIPULATED AND AGREED that this stipulation may be signed
in counterparts, and facsimile and e-mail signatures will constitute originals for purposes of this
stipulation.

Dated: September /3 , 2017 Dated: September /Z. 2017

CRAVATH, SWAINE & MOORE LLP KRAMER LEVIN NAFTALIS &
FRANKEL LLP

By: By:
(gjbert H. Baron Harold P. Wftiberger
Rory A. Leraris Susan Jaispcmot
Members of the Firm Leah S. Friedman

Worldwide Plaza 1 177 Avenue of the Americas

825 Eighth Avenue New York, NY 10036 :
New York, NY 10019 (212)715-9100
(212) 474-1000
LONGO & DAPICE
GOLDBERG & RIMBERG PLLC Mark A. Longo, Esq.
Israel Goldberg 26 Court Street, Suite 1 700
Steven A. Weg Brooklyn, NY 11242
115 Broadway, 3rd Floor (718)722-7300
New York, NY 10006
(212) 697-3250 Attorneys for Defendant Forest City Ratner
Companies, LLC
DOMENIC M. RECCHIA, JR.
172 Gravesend Neck Road
Brooklyn, NY 1 1223
(718) 336-5550

Attorneys for Plaintiff A.J. Richard & Sons,

Inc.

3
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 FILED: KINGS COUNTY CLERK 09/18/2017 10:23 AM INDEX NO. 514736/2015
NYSCEF DOC. NO. 120 RECEIVED NYSCEF: 09/18/2017
INDEX NO.: 514736 YEAR 2015 *
*
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
A.J. RICHARD & SONS, INC.

Plaintiff,
- against -

FOREST CITY RATNER COMPANIES. LLC

Defendant.

STIPULATION FURTHER EXTENDING DISCLOSURE DEADLINES

DOMENIC M. RECCHIA, JR.

Attorney for Plaintiff
172 Gravesend Neck Road
Brooklyn, New York 11223

_ (718) 336-5550
FAX (718) 336-8466 _
TO: ATTORNEYS FOR:

SERVICE OF A COPY OF THE WITHIN IS HEREBY ADMITTED

DATED:
ATTORNEYS FOR

PLEASE TAKE NOTICE

/ NOTICE OF ENTRY
that the within is a (certified) copy of an
named Court on ,20
_
entered in the office of the within

l that an Order of which the within is a true copy will be presented for settlement to the
NOTICE OF SETTLEMENT Hon. , one of the judges of the within named Court, at on
_
20 , at 9:30 a.m.

DATED:
BROOKLYN, NEW YORK

; DOMENIC M. RECCHIA, JR.

Attorney for Plaintiff
172 Gravesend Neck Road
Brooklyn, New York 1 1223

I-

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